Vought’s New CFPB Plan Leaves Opening for Agency Resurgence

The Trump administration’s new plan to eliminate more than half of the Consumer Financial Protection Bureau’s remaining staff will drastically reduce oversight of mortgage, credit reporting, and other markets—but it also leaves a path to reviving the agency.

The CFPB would be left with around 550 people to police consumer finance markets, handle consumer complaints, protect military personnel borrowers, and carry out other functions under the latest plan approved by acting Director Russell Vought and submitted to the US Court of Appeals for the District of Columbia Circuit for approval this week.

That would mean eliminating hundreds of positions in the CFPB’s supervision and enforcement units, which the National Treasury Employees Union—representing most of the agency’s employees—says will lead to significant consumer harm.

“Vought’s insistence that CFPB can meet its statutory obligations with only one-third of the staff is laughable, and an insult to the intelligence of the judges,” Cat Farman, the president of the CFPB’s union, which is a part of the NTEU, said in a Thursday statement. “Everyone knows Vought doesn’t want CFPB to exist at all.”

But the new plan marks a stark departure from Vought’s repeated efforts last year to dismiss up to 90% of the agency’s staff.

The cuts may still be “draconian,” but the latest proposal “is almost the best result for the staff and the union that could be achieved under the circumstances,” said Mike Silver, a Spencer Fane partner and former CFPB regulatory attorney.

The agency in its court filing said it will still be able to handle customer complaints and engage in a stacked rulemaking agenda, among other statutory requirements. It didn’t respond to a request for additional comment.

The CFPB had around 1,500 staff members when Vought took over in February 2025 and now has fewer than 1,200 on board.

The NTEU along with other plaintiffs sued to block Vought’s plan to fully dismantle the CFPB, established by Congress following the 2008 financial crisis.

Lacking Trust

The CFPB filed its latest workforce reduction plan March 31 in a bid to lift or change a preliminary injunction last year from Judge Amy Berman Jackson of the US District Court for the District of Columbia—subsequently modified by the DC Circuit—to block mass firings.

The Trump administration is likely to face delays on its new proposal, however.

The union will have time to respond and there’s a chance the plan will be sent to Jackson for further review, Silver said.

If the case goes to Jackson’s court, the union may be able to get discovery to determine exactly what Vought plans to do with the CFPB in the long-term. There’s already a lot of distrust, given his past actions.

“This layoff plan retains some core functions, but, absent court review, there is nothing stopping CFPB leadership from firing the remaining staff down the line,” Tom Feltner, the associate director of consumer policy at the Americans for Financial Reform Education Fund and a former CFPB official, said in a statement.

Path Forward

The DC Circuit made clear at a February hearing that it doesn’t want to be in the business of monitoring day-to-day operations at the CFPB, even as it seeks to ensure the agency is meeting its statutory requirements.

Vought’s plan, if implemented, is a starting point for meeting the court’s requirements.

“It is clear to me that the CFPB has abandoned any hope of shuttering the CFPB,” said Alan Kaplinsky, a senior counsel at Ballard Spahr LLP who advises banks and other lenders.

The workforce reduction plan is a “white flag” from Trump officials that also leaves open a path to reviving the agency under a Democratic administration, Silver said, especially if lawmakers ultimately decide to restore CFPB funding levels that Republicans cut by nearly half last year.

“This does give some finality and closure about what is going to happen to the CFPB for the next two-and-a-half years,” he said.

The case is NTEU v. Vought, D.C. Cir., No. 25-05091, motion 3/31/26.